EIA analysis of coal mining project by M/s Jayaswals Neco Limited

Background of the technical report
Jayaswals Neco Ltd. (JNL) is planning to set up a 1.2 million tonnes per annum (TPA) coal mining project in Raigarh district of Chattisgarh. On behalf of the local community there, two activists requested the Centre for Science and Environment to technically evaluate the Rapid Environment Impact Assessment done for the project. These activists are Raghuveer Pradhan, associated with Ekta Parishad and Ramesh Agrawal, of Jan Chetna (an NGO working on social and environmental issues).

This report is a technical evaluation of the Environment Impact Assessment (EIA) document submitted by JNL as part of the clearance process for a 1.2 million tonnes per annum coal mining project, Raigarh. Nagpur-based Enviro Techno Consult has conducted the EIA.

Mining is proposed in the Gare IV/8 mining block, which is part of the Mand-Raigarh coalfields. The EIA report for this project has been prepared based on the TORs set by MoEF (pages 1-3). The study area of the EIA includes a core zone (which is the mine lease area), and a buffer zone that includes the area within a 10-km radius of the lease area (page 23).

Salient features of the project

Location: The area surrounding the project site is rich in coal. Many sub blocks of the Gare block (for instance Gare IV/1-Gare IV/7) are either operating or in the process of being leased out for mining. Also, industries based on coal have also come up. The 4x250 MW OP Jindal Super Thermal Power Plant is an example. The ambient air quality near the proposed mines is already quite poor, and an assessment of the impact of more mining activity in this area is very important.

Land use pattern: The project requires 491 hectares of land (page 7). The region surrounding the proposed site is heavily forested. According to the EIA report, the north and northeastern part of the lease area is covered under forests (page 7). Out of the total land requirement, 45.7 per cent is forestland (analysis based on data from page 7). In the buffer zone (consisting of area within a 10-km radius of the proposed site), 46 per cent of the total area is under reserved forests, protected forests or village forests (page 24). According to satellite imagery, this figure is approximately 41 per cent (page 25). In any case, all the available data goes on to show that the region is heavily forested. The EIA report also reports that there has been encroachment of forestland in the last decade (page 25).

Figures in the EIA report indicate that agriculture is a major occupation in the study area. 42 per cent of the area is agricultural land, either irrigated or rainfed (page 24). More than 90 per cent of the marginal workers in the study areas are either cultivators or agricultural labourers (page 59). From the available data on land use pattern in the study area, it is clear that the project is likely to impact local biodiversity, the forest ecology, as well as the agricultural base of the local community.

Human habitation: There is one village in the core zone, Khamaria, below which underground mining will be carried out (page 58). This village is likely to face the brunt of the mining activity, at least in terms of noise and air pollution, and also in terms of the impacts due to blasting and ground vibrations. The density of population in the study area is 108 persons per square kilometre (page 58), which is lower than the Indian average figure of 324 persons per square kilometre (as per Census of India 2001).

Environmental impact of the project and the analysis of the EIA report.

1. Impact of water consumption by the project

i. Impact on local groundwater resources

According to the EIA report, open cast coal mining by JNL will involve breaching of the groundwater table. The depth of the groundwater table is as low as the 1.4 metres below ground level during the post-monsoon period, and even during the pre-monsoon period, the water table can be as low as 3 metres (page 45). The minimum quarry depth during open cast mining is 7 metres, while the maximum can go up to 64 metres (page 10). It is therefore obvious that the mining project will cause large-scale breaching of the groundwater table.

The EIA report states that the rate of dewatering from the mine pit should not exceed 65 per cent of the rate of groundwater recharge in the mine lease area, so as to maintain the “safe” groundwater category of the mine lease area (pages 50, 66). According to this criterion, the rate of dewatering should be 1,787m3/day (page 50). However, no where in the EIA report has the actual rate of discharge from the mine pit been mentioned. There is therefore no information on whether the rate of discharge will be higher than this benchmark or not. It has been mentioned that the project’s requirement of 550 m3 of water/day will be met from the mine pits (page 50). However, there is every possibility that much more water will be generated.

On the basis of the available information, no definite conclusion can be made regarding the impact on quantity of groundwater resources. The large-scale underground mining activity also has the potential of altering the groundwater regime. However, the EIA report has made no mention of this.

The EIA report has done an analysis of the impact on local groundwater resources by doing a groundwater balance; stating that the stage of groundwater development is just 30 per cent (pages 45-46). According to the EIA report, the total groundwater recharge in the study area is 0.966 MCM, while the current groundwater utilisation is 0.29 MCM.

Details of how the groundwater balance was done are not provided in the EIA report. From the available information, the factors that have been taken into account are available groundwater resources (data from the Central Ground Water Board and the Chattisgarh Ground Water Survey Circle), and consumption for domestic as well as irrigation purposes. However, while assessing the impact on groundwater resources in the study area, the cumulative impact of water consumption by various industrial sources has not been taken into account. The groundwater balance has also not calculated groundwater utilisation by others users – for instance groundwater consumption by cattle, water utilisation in forest areas, water discharged into surrounding mine pits, and groundwater losses. Also, there is no information on whether recharge has been calculated taking into account recharge through water spread areas, recharge through irrigated areas, and recharge through water discharged from surrounding mine pits. Such a detailed analysis is required in a heavily mined area, without which a correct analysis cannot be done.

All the rivers in the region (the Kelo, Mand and Kurkut rivers), which are important sources of water in the region, are already heavily stressed. The upcoming industries in the district (and there are a considerable number, since Raigarh is an emerging industrial hub) are increasingly depending on groundwater. As a consequence the region is beginning to face a groundwater crisis. In fact, when Jindal Power Ltd. asked for permission to dig 40 tubewells for its Super Thermal Power Plant, the Groundwater Survey Department recommended against giving this permission – stating the possible adverse impacts on the local groundwater regime (ref: letter dated 15/04/2006). Large-scale mining activity, involving underground mining as well as breaching of the groundwater table, will have a huge impact on local groundwater resources. This cumulative impact has not been assessed by the EIA.

ii. Impact of wastewater disposal

According to the EIA, water from the mine pits can be used for agriculture or drinking after treatment, and can also be used for dust suppression within the project’s premises. The EIA report also states that there is very little possibility of mine pit water reaching the Kelo river (page 66). However, elsewhere in the same report, it is stated that most of mine pit water will be discharged in the Kelo (page 77). Therefore, it is most likely that mine pit water will reach the Kelo.

The report states that the Kelo already receives substantial water from discharges from the adjoining mines even during the lean season, and therefore has a good flow rate throughout the year (page 66). While the report claims that the high flow rate of the Kelo will ensure that there will be no siltation, this might not be the case.

According to the EIA report itself, mine pit water has substantially higher TDS (Total Dissolved Solids) values – for instance, water in the Bendra nullah, which receives water from many mine pits, has a TDS value of 192 mg/l, whereas the Kelo has a TDS value which is 2.6 times lower; just 73 mg/l (page 50). When the Bendra joins the Kelo, the TDS more than doubles (page 50). If one assumes that 1,237 m3/day of water from the mine pit is discharged into the Kelo (assuming that a total of 1,787 m3/day is discharged by the project, and that 550 m3/day is consumed in-house), then 237 kilograms of suspended solids will be discharged into the Kelo every day. A similar increase will also be seen in the case of ionic loads. Therefore, based on data provided in the EIA, it is not accurate to say that the mine pit water will not increase siltation and water pollution in the Kelo.

2. Impact of the project on local air quality

Mining activity can be hugely air polluting, given the vast quantities of material handled. This is specially so if the project under consideration is proposed to come up in a heavily mined area, as is the case under consideration. Assessing the impact of air pollutants is therefore very important. In particular, suspended particulates have to be estimated, and their impact assessed.

i. Fugitive emissions: Regulations governing air pollution concentrate on point source emissions – however, emissions from non-point sources, i.e emissions during material storage, transportation and handling are equally important to monitor and control. In fact, often, fugitive emissions are more harmful than particulate emissions, because of the sheer magnitude of the emissions.

The EIA report for the proposed project has made estimations of fugitive emissions. The emission potential from top soil removal, drilling, blasting, transportation, material handling, and also from the coal handling plant have been estimated. However, emissions from material (in particular coal and overburden) storage have not been estimated. Estimations of emissions have only been made in case of the coal handling plant (CHP). Coal might be stored before it is taken to the CHP. According to the EIA report, coal will be brought to the CHP through tippers (page 76) – between the time coal is mined out and brought to the CHP, coal will be stored. Similarly, overburden will also be stored. Fugitive emission generation from such storage can be substantial.

According to the EIA report, approximately 3.5 MTPA (1.2 MTPA of coal and 2.3 MTPA of overburden) will be handled every year (calculated based on information provided in pages 14-15 and assuming a density of overburden as 1.5 gm/cm3, as given in page 26). Assuming that just 0.1 per cent of this material escapes in the atmosphere in the form of dust, this will mean approximately 3,510 tonnes of dust per annum. If 0.5 per cent is lost as fugitive dust, this figure jumps to approximately 17,550 tonnes of dust per annum.

In many of the cases, the Environment Management Plan (EMP) suggests adequate steps for dust suppression. However, in some cases, better steps could have been suggested. For instance, during drilling, water spraying has been suggested (page 86). For better emission control, bag filters could have been attached to the drilling machines. Similarly, covered storages and covered conveyor belts could have been suggested.

Another major area which has not been covered in the EMP is the fugitive emissions from the final loading of coal at the railway siding. This is one of the major areas where high amount of fugitive emissions can be generated. Mechanical handling systems and conversion of non-point sources to point sources, as well as water spraying could go a long way in controlling emissions at this juncture.

ii. Monitoring impact of air pollution: The EIA has been conducted during the pre-monsoon season (March-June 2006). However, for proper evaluation of air pollution impacts, monitoring and data collection should be done during the winter season also, when the impacts of air pollution are most prominent. Therefore, given the large pollution potential of the proposed project and the sensitive nature of the project site, a rapid EIA with one-season data collection is insufficient.

3. Local biodiversity

The region surrounding the proposed site is rich in biodiversity. Nearly half of the area in the buffer zone is forested (page 24). According to the EIA report, a very small proportion of the forested area will be diverted for non-forest purposes; just 57 hectares out of the total of 224 hectares of forest land (page 66). However, there will be an impact of mining activity on local biodiversity even there is no diversion of forest land, as has been seen in the case of forests located near many sponge iron plants in Chhattisgarh, Orissa and Jharkhand.

According to the EIA report, wildlife in the study area includes bear, bandar and pea fowl, all of whom are included in Schedule I of the Wildlife Protection Act 1972 (page 57-58). Leopards are also found in the study area.

Regarding flora, the information in the EIA report is insufficient. The EIA report has not done a tree flora vegetation analysis. Also, the EIA report has not calculated importance value indices (IVI), and the diversity indices of tree species found in the study area.

Many species (especially mahua) which are of very high economic value to the local community are found in the study area. There are allegations (Point 3.2 of objections submitted to the Chhattisgarh Environment Conservation Board on January 29, 2005) that emissions from Jindal Steel and Power Ltd.’s existing steel plant in Raigarh have caused a reduction in the yields of mahua crop in the surrounding areas. It is therefore important to conduct a thorough study of the exact impact of various pollutants on mahua as well as other vegetation in the region. No such analysis has been presented in the EIA report.

4. Noise

The impact of noise will be important in the case of project, since one village is located within the lease area itself. Settlements exist just 66 metres from the proposed quarry (page 11). In fact, underground mining will be conducted under Kahamaria. According to data provided in the EIA report, the noise levels in Khamaria village already exceed both the daytime as well as the nighttime permissible noise limits (page 53). Any new facility will obviously increase this impact. Considerable noise and vibrations will be generated by mining activity, and this additional load will have a serious impact on the local community.

5. Disaster management

Coal mining, especially underground coal mining, is susceptible to accidents and other occupational hazards. Fatal accidents of many kinds can happen during underground mining – roof collapse, flooding, suffocation due to methane, carbon dioxide and carbon monoxide to name a few. Spontaneous combustion of coal is also an issue. Therefore a comprehensive disaster management plan, and risk management pertinent to underground mining should have been part of the EMP. This would include details of various preventive measures taken, and measures taken for early detection, warning and evacuation. However, while open cast mining has been dealt with, underground mining has been completely ignored. Given the high disaster potential, this is unacceptable.

Conclusion

JNL’s proposed integrated steel plant is a large-scale project. There are two major impact areas of the project – impact on local water regime (both groundwater and surface water), and impact on forests and local biodiversity. Regarding impact on local water resources, the EIA tries to make an impact assessment, but the assessment is not comprehensive enough, and fails to provide a proper assessment.

The project is coming up in a forested area. It is the site of the project that will play the largest role in deciding its overall environmental impact. The region is eco-sensitive for many reasons – the forests form the base of peoples’ livelihood in this predominantly tribal area (mahua in particular is central to the local economy), the forests are also home to many protected species and moreover forests play an extremely important role in groundwater recharging. Air pollutants can have a major adverse impact on local biodiversity, even if substantial tracts of forest land are not diverted. The analysis provided in the EIA underestimates the possible impact due to air pollution, as is evident from the analysis presented in this report.

The ecology in the area is facing the impacts of many industrial projects – including the 4x250 MW Super Thermal Power Plant, many coal mines, and many sponge iron plants. Therefore, in considering the environmental impact of this proposed project, the larger picture has to be kept in mind. The impact on the local ecology – whether on the forests, or on the local groundwater regime - will be cumulative.